TAX AUDIT & LITIGATION
Tax Audits and Litigation. As an estate planning attorney, I place a substantial emphasis on avoiding tax audits or litigation. I never recommend a tax strategy that I do not consider a legitimate one. At the same time, some strategies are more prone to audit or challenge by the IRS than others, and before recommending any strategy to a client I will apprise the client if I believe that strategy is more likely than another to carry a risk of audit or result in litigation. Having said that, if an estate plan that I have drafted is audited or challenged, I am prepared to represent you in such audit or litigation. From the time of my early career in which I was a tax attorney in a litigation branch of the Justice Department in Washington, DC, I have engaged in litigation, and am prepared to provide competent representation to you if the circumstances arise.
I am also prepared and willing to represent you if you first come to me, having been assessed a deficiency or proposed deficiency by the Internal Revenue Service, and if you seek representation in negotiating with the IRS, or if you otherwise seek representation in an audit being conducted by the IRS or in an appeal within the IRS of a deficiency determination; and I will represent you in any litigation necessary to resolve such controversy in the tax court or federal court.